[Home](/)/[Resources](/resources)/Japan Home Appliance Recycling Law JapanEPR / recycling # Japan Home Appliance Recycling Law (HARL): Compliance for Electronics Makers Japan's Home Appliance Recycling Law (家電リサイクル法) requires manufacturers and importers of four designated appliance categories to fund the collection and recycling of those products at end of life. Unlike many European EPR systems, the recycling fee is paid by the consumer at the point of disposal — but the obligation to set the fee, label products, and arrange recycling infrastructure sits squarely with the producer. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Fjapan-home-appliance-recycling-law) At a glance Law Home Appliance Recycling Law (HARL) Administrator METI / MOE Designated categories 4 product groups Fee model Consumer-paid at disposal ## What HARL covers and who it applies to ### The four designated product groups HARL (家電リサイクル法), enacted in 1998 and effective from 2001, designates four product groups for mandatory collection and recycling: (1) air conditioners (including separate-type multi-split systems), (2) televisions (CRT, LCD, and plasma), (3) refrigerators and freezers, and (4) washing machines and clothes dryers. Products outside these four categories — including computers, smartphones, and small appliances — fall under separate legislation (the Small Home Appliance Recycling Act of 2013) or are not yet subject to mandatory recycling obligations. ### Manufacturer and importer classification Under HARL, any company that manufactures or imports designated appliances for sale in Japan is classified as a 'manufacturer/importer' and bears recycling obligations. If you sell designated appliances under your own brand — even if manufactured by a third-party OEM — you carry the manufacturer/importer obligation. Japanese distributors that import and rebrand foreign-made appliances also bear the obligation. Selling through a Japanese trading company or distributor does not automatically transfer the obligation — who bears it depends on the commercial structure. ### Recycling fee model HARL operates on a 'consumer pays at disposal' model, not an advance recycling fee collected at point of sale. When a consumer discards a designated appliance, they pay a recycling fee to the retailer collecting the old unit. That fee is passed through the system to the designated manufacturer/importer responsible for recycling that product. Recycling fee schedules are published by each manufacturer/importer and are public — they reflect the actual cost of collection, transport, and recycling. ### Take-back and transport obligations Retailers who sold designated appliances are obligated to collect them when consumers return old units for disposal. Manufacturers and importers are obligated to accept collected units from retailers and arrange for transport to designated recycling facilities. HARL designates recycling facilities by product category — manufacturers must contract with facilities authorised under the Act. Two industry consortia operate the practical recycling infrastructure: one covering major Japanese manufacturers (the 'A consortium') and one covering other manufacturers and importers (the 'B consortium'). ## How to meet HARL obligations as an importer 01 Confirm whether your product falls within one of the four designated HARL categories. Product boundary cases — for example, portable air conditioners, combination washer-dryer units, or commercial-grade refrigeration equipment — require review against the ministerial classification guidance published by METI and MOE. 02 Register as a manufacturer/importer with the Japan Electrical Manufacturers' Association (JEMA) or the relevant industry body for your product category. HARL assigns each registered manufacturer/importer a recycling obligation that is tracked against their historical production and import volumes. 03 Determine the applicable recycling fee for each designated product model. Recycling fees are set by the manufacturer/importer based on product type and disclosed publicly. Fees differ by product category (air conditioners, TVs, refrigerators, washing machines) and, for TVs, by screen size. Update fees if your recycling cost structure changes. 04 Label designated products with recycling fee information. HARL requires that products display the applicable recycling fee so that consumers are aware of end-of-life disposal costs at the point of purchase. The labelling requirement applies to the product or its packaging. 05 Maintain contractual relationships with authorised HARL collection points and recycling facilities. Most foreign manufacturers and importers join the B consortium, which provides access to the national collection and recycling network without requiring individual facility contracts. Consortium membership fees are based on sales volumes. ## Frequently asked questions ### What products are covered under Japan's Home Appliance Recycling Law? HARL covers four product categories: air conditioners, televisions (all display technologies including CRT, LCD, and plasma), refrigerators and freezers, and washing machines and clothes dryers. All other consumer electronics — including computers, monitors, smartphones, audio equipment, and small kitchen appliances — fall outside HARL. The Small Home Appliance Recycling Act (小型家電リサイクル法), enacted in 2013, covers smaller electronics on a voluntary municipal collection basis and does not impose producer recycling fees. ### Who pays the recycling fee under HARL — the manufacturer or the consumer? The consumer pays the recycling fee at the point of disposal, not at point of sale. When a consumer disposes of a designated appliance, they pay a fee to the collecting retailer. The fee is set by each manufacturer/importer to cover the cost of collection, transport, and recycling. This is structurally different from some European EPR systems where an advance recycling contribution is embedded in the product price at sale. The practical effect is that consumers bear the end-of-life cost directly and visibly, which METI intends as a disposal-reduction incentive. ### What happens if the original manufacturer no longer exists or has left the Japanese market? HARL addresses the orphan product problem through the B consortium. When a manufacturer/importer has ceased operations or cannot be identified, the recycling obligation for collected units is distributed across the B consortium members in proportion to their historical market shares. This means active importers indirectly bear some of the recycling cost for orphan products. For foreign companies that have exited or are considering exiting the Japanese market, any registered HARL obligation should be formally transferred or terminated — failing to do so can create ongoing liability. ### How does HARL compare to the EU's WEEE Directive? HARL and WEEE share the extended producer responsibility (EPR) principle but differ in scope and structure. WEEE covers a very broad range of electrical and electronic equipment across multiple categories. HARL covers only four product categories. WEEE uses a national producer register with advance financial guarantee requirements; HARL uses a disclosed recycling fee collected at disposal. WEEE imposes recycling rate targets across the whole national market; HARL tracks obligations at the individual manufacturer/importer level. For a company already compliant with WEEE, meeting HARL requires separate registration and fee-setting in Japan — there is no mutual recognition. **Disclaimer:** Educational resource only. Regulatory requirements change and vary by product category. Consult an accredited test laboratory or qualified compliance engineer before making certification decisions. 🇯🇵 Japan roadmap for your product Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take your product through 🇯🇵 Japan compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/42-japan-pse-marking-ecommerce-electronics-sellers)[Prefer to read? 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